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This California Privacy Statement is for California Residents only and supplements [the Privacy Notice]. This policy describes the personal information that Great Lakes Credit Union (“we,” “our,” or “us”) collects in the course of its business, explains how this information is collected, used, shared, and disclosed, describes rights provided by the California Consumer Privacy Act of 2018 (“CCPA”) to (“consumers” or “you”) regarding their personal information, and explains how consumers can exercise those rights.
We may collect, use, or share your personal information. Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“personal information”). “Personal information” does not include: (1) publicly available information, such as information that is lawfully made available from federal, state, or local records, and (2) de-identified or aggregate consumer information.
With a limited exception, and as noted in other sections of this privacy policy, certain provisions of the CCPA do not apply to:
The CCPA requires us to disclose certain information regarding our collection, use, and sharing of personal information.
Collecting Your Personal Information
In the past 12 months, we have collected the following categories of personal information:
In the past 12 months, we have collected personal information from the following categories of sources:
We may collect your personal information for the following business or commercial purposes:
Disclosing Your Personal Information for a Business or Commercial Purpose
We may disclose your personal information to service providers and third parties in order to carry out specific business or commercial purposes. In the preceding 12 months, we have disclosed the following categories of consumer personal information for business or commercial purposes to service providers and the following categories of third parties:
In the preceding twelve (12) months, we have not sold any personal information. In addition, we do not sell personal information. Also, it is our business practice not to sell the personal information of minors under 16 years of age and we have no actual knowledge of doing so.
As described in more detail below, the CCPA provides you with certain rights regarding the collection, use, and disclosure of your personal information. The CCPA also provides consumers with certain rights (for example, opt-out rights) if a business sells personal information, which we do not do.
The Right to Know About Personal Information Collected, Used, or Disclosed
You have the right to request that we provide you with certain information about the personal information we collect, use, or disclose about you as well as the categories and specific pieces of information that we have collected about you in the 12 months before your submission of a verifiable consumer request. Specifically, you have the right to request the following information:
A household may request to know aggregate household personal information by submitting a verifiable consumer request. Also, unless the household has a password-protected account, if all consumers in a household jointly request access to specific pieces of information for the household, we can individually verify the identity of all the members of the household, and we can verify that each member is a current member of the household, then we will comply with the request.
However, there is certain information that we will not disclose to you. This information includes but is not limited to your Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answer, or unique biometric data generated from measurements or technical analysis of human characteristics.
This right does not apply to Business Consumers.
The Right to Request Deletion of Personal Information
You have the right to request that we delete any personal information that we have collected from you and maintained about you. Once we receive and confirm your verifiable consumer request, if we determine that we must comply with a deletion request and delete your personal information from our records, we will also direct any service providers we work with to also delete your personal information from their records. If we store any of your personal information in our archived or back-up systems, we will delete your information once the systems are accessed, restored, and/or used.
A household may request the deletion of aggregate household personal information by submitting a verifiable consumer request. In addition, unless the household has a password-protected account, if all consumers in a household jointly request deletion of household personal information, we can individually verify the identity of all the members of the household, and we can verify that each member is a current member of the household, then we will comply with the request.
Please note that we may deny your deletion request for a number of different reasons, which are identified in the CCPA.
Submitting a Verifiable Request to Know or Request to Delete
To exercise your Right to Know or your Right to Delete, please submit a verifiable consumer request to us by either:
Only you (or an authorized agent) may make a verifiable consumer request. You may also make a verifiable consumer request on behalf of your minor child.Verifying Your Identity
Once you submit your verifiable consumer request, we will verify your identity by matching the information you provided us with information in our systems. If you submit a request to know specific pieces of personal information or a request to delete certain information, in addition to verifying your identity with information we have on file, you also may be required to submit a signed declaration under penalty of perjury stating that the requestor is the consumer whose personal information is the subject of the request. If we are unable to respond to your request for specific pieces of information, we will evaluate your request as if it is a request to know the categories of personal information that we have collected about you.
If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account and we will also require you to re-authenticate yourself before we disclose your personal information. If we suspect fraudulent or malicious activity on or from your account, we will not comply with your request until we perform further verification to determine whether your request is authentic and you are the person about whom we have collected the personal information.
We will generally avoid requesting additional information from you to verify you. However, if we cannot verify your identity based on the information we currently maintain, we may request additional information from you, which will only be used to verify your identity and for security or fraud-prevention purposes. We will delete any new personal information we collect to verify your identity as soon as practical after processing your request unless otherwise required by the CCPA.
Generally, if we are unable to verify your identity, we will deny your request and inform you of our inability to verify your identity and explain why we were unable to do so.
Please note that we are only required to respond to your request for access to your personal information twice within a 12-month period. Responding to Your Request to Know or Delete
Once we receive your verifiable consumer request, we will confirm our receipt of your request within 10 business days and provide you with additional information about how we will process the request. Our goal is to respond to your request within 45 calendar days of receiving the request, beginning on the day we receive the request. However, in the event that we need more time (up to 90 calendar days) to respond to your request, we will provide you with notice and an explanation of the reasons that we will take more than 45 calendar days to respond. Any disclosures we provide will cover the 12-month period preceding the verifiable consumer request’s receipt. If we are unable to comply with a given request, we will provide you with a response explaining why we have not taken action on your request and identifying any rights you may have to appeal the decision.
We will not charge you or your authorized agent to verify your identity. In addition, we will not charge you or your authorized agent a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Authorized Agent for Requests
You may designate an authorized agent to make a request on your behalf. Unless you have a power of attorney, if you would like to use an authorized agent, which is an individual or business registered with the Secretary of State that you have authorized to act on your behalf, to submit a request, you must provide the authorized agent with written and signed permission to do so, verify your own identity directly with us, and directly confirm that you provided the authorized agent with permission to submit the request. We may deny a request from an authorized agent that does not submit proof that they are authorized to act on your behalf.
We will not discriminate against you for exercising any of your CCPA rights. For example, unless otherwise permitted by the CCPA, we will not:
We are required by law to update this California Privacy Statement at least once each year. This California Privacy Statement was last updated on June 30, 2020.
If you have any questions regarding our privacy policies, our California Privacy Statement, the ways in which we collect, use, and disclose your personal information, or how to exercise your rights under the CCPA, please do not hesitate to contact us at:
Phone: 1-800-982-7850Website: www.glcu.org/ccpaEmail: privacy at glcu dot orgPostal Address: P.O. Box 1289, Bannockburn, IL 60015Attn: Risk Management, Senior Manager of Risk & Governance
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